Railroad Retirement Board v. Duquesne Warehouse Co.

Background

Duquesne Warehouse Company, a corporation wholly owned by the Pennsylvania Railroad, operated warehouses on the railroad’s sidings and handled goods like sugar and newsprint. The Railroad Retirement Board found Duquesne to be an "employer" under two federal laws that provide railroad retirement and unemployment benefits. Duquesne sued to set aside those Board orders; lower courts reached conflicting results, producing the legal questions the Court reviewed.

Reasoning

The central question was whether Duquesne’s work counts as services "in connection with" railroad transportation so that its employees are covered by the benefit laws. The Court explained that the statutory phrases at least include activities that would be transportation services under the Interstate Commerce Act. Because Duquesne regularly unloaded, stored, and reloaded carload shipments and performed similar handling services that the railroad itself could perform and charge for, those activities fall within the Acts’ definition of employer. The Court therefore treated Duquesne as an employer for the acts at issue and resolved the conflicting lower-court rulings accordingly.

Real world impact

Workers who perform loading, unloading, storage, and related handling for railroad-owned warehouses like Duquesne can be covered by the Railroad Retirement and Railroad Unemployment Insurance Acts. The decision rests on the services the railroad could perform itself, and the Court did not decide whether every other service performed by affiliates is covered, so some questions remain for future cases.